Curio Labs Limited (“Curio”, “we”, “us” or “our”) respects your privacy and takes the protection of your personal information very seriously. This policy describes the information we hold about you, how it is used and with whom we may or may not share it. It also informs you about your privacy rights and how the law protects you.
Curio Labs Limited is the controller of the personal information it processes and our Director is responsible for overseeing questions relating to this policy. If you have any questions about this policy, or wish to exercise your privacy rights, please contact:Our Director at firstname.lastname@example.org.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisor authority in the UK for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data that we collect
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer information about you which we have grouped together as follows:
- Identity Data including your name
- Contact Data including your email address, telephone number and billing address
- Financial Data including bank account and payment card details and method of payment preference
- Transaction Data including details about payments between us and other details of products and services you have purchased from us
- Technical Data including your IP address, your login data, device details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any of our services
- Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
- Usage Data including information about how you use our website and services including your track selection, duration of listening, listening history, your library and search queries
- Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
We also collect and use Aggregated Data to track the use of our services. This data is derived from your personal data but is not considered personal data from a legal point of view as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to understand how popular articles are.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you our services). In this case, we may have to cancel our service to you but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us online, by phone, email or otherwise. This includes personal data you provide when you:
- apply to trial our services;
- create an account with us;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers based within or outside the EU;
- search information providers such as Google based inside OR outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside OR outside the EU.
- Technical Data from the following parties:
Use of information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests and where we need to comply with a legal or regulatory obligation.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data for any of the purposes set out below:
- To register you as a new customer
- To process and deliver your order including:
- Manage payments, fees and charges
- Collect and recover money owed to us
- To manage our relationship with you which will include:
- Asking you to leave a review or provide feedback
- To administer and protect our business and services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
- To deliver relevant content and services to you and measure or understand the effectiveness of the service we provide
- To use data analytics to improve our products/services, marketing, customer relationships and experiences To make suggestions and recommendations to you about content that may be of interest to youIf you would like to know more about how and why we use personal data, please contact us at firstname.lastname@example.org
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details via our website and, in each case, you have not opted out of receiving that marketing.
We do not share or sell any personal information or information that may personally identify you to any third party.
You can ask us to stop sending you marketing messages at any time by contacting us at any time at email@example.com
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with external third parties for the purposes set out in the table above. These third parties may be:
- service providers acting as processors based within The EU and in The United States of America, who provide IT and system administration services.
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in The UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom] who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
A few of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will we use your personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.